Godolphin Australia Pty Ltd v Chief Commissioner of State RevenueCitation:[2024] HCA 20Before:Gageler CJ, Gordon, Edelman, Steward, Jagot JJDate:05 Jun 2024Case Number:S130/2023Read more

Godolphin Australia Pty Ltd v Chief Commissioner of State RevenueCitation:[2024] HCA 20Before:Gageler CJ, Gordon, Edelman, Steward, Jagot JJDate:05 Jun 2024Case Number:S130/2023Read more

The Court held that the dominant use requirement in s 10AA(3)(b) applies to the composite phrase, meaning the land must be dominantly used for the maintenance of animals for the purpose of sale, not merely for maintenance of animals alone.

Parties
Applicant: Unknown Applicant; Respondent: Unknown Respondent
Jurisdiction
Australia
Judgment Date
05 June 2024
Procedural Posture
Statutory Appeal / Judgment
Outcome
Appeal dismissed
Legal Topics
Land Tax, Statutory Exemption, Primary Production, Statutory Interpretation

Case Brief

Summary, issues, holding and outcome

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Parties

Unknown Applicant

Applicant

Unknown Respondent

Respondent

Procedural Posture

Statutory Appeal / Judgment

  1. 1 Whether the dominant use requirement in s 10AA(3)(b) of the Land Tax Management Act 1956 (NSW) applies to both the maintenance of animals and the purpose of sale.
  2. 2 Whether 'dominant' qualifies only the use of land or the composite 'use-for-a-purpose' phrase.

Ratio Decidendi

The Court held that the dominant use requirement in s 10AA(3)(b) applies to the composite phrase, meaning the land must be dominantly used for the maintenance of animals for the purpose of sale, not merely for maintenance of animals alone.

Court Disposition

Appeal dismissed

Orders

  • The exemption under s 10AA(1) is not available to the applicant.
  • Applicant to pay costs.